Challenges and Solutions Barbara Hart Pennsylvania Coalition Against Domestic Violence JustProj1@aol.com Year N/A Pennsylvania Coalition Against Domestic Violence

In the last year, I've had the privilege of traveling across the country to talk with a variety of folks from the justice system (e.g. advocates, police officers, prosecutors, judges, court administrators, U.S. attorneys, corrections personnel, as well as, law professors, batterer intervention service providers and battered women), about the remedies offered by the Violence Against Women Act of 1994, and most particularly the full faith and credit provision, 18 U. S. C. 2265. Although participants in the various conferences have been enthusiastic about investigating the statute and its application, they report that their peers have remained skeptical, asking why such extraordinary attention should be paid to inter-jurisdictional enforcement of protection orders. It thus became one of my tasks to offer rationale for the extensive efforts that must be harnessed and focused to assure full faith and credit (FFC) of protection orders wherever victims seek enforcement and safety. The rationale I offered evolved over the course of several presentations to include:

About 23 years ago, attorneys in Legal Services offices in New York and Pennsylvania began to document the number of clients, particularly divorce and custody clients, who reported that they were victims of domestic violence, that the level of violence had increased since they had told their partners of their plans to divorce and that those who had separated were being stalked by their spouses/partners after leaving. Over half of divorce clients reported domestic violence at some point in their marriages. It was the era of "fault" divorces, long waiting lists and often protracted litigation with little economic relief for dependent spouses (and some would remind me that except for the removal of the "fault" bases for divorce, these problems remain). Battered clients (and most were women) had no recourse at law to achieve protection as the criminal side of the justice system did not consider domestic violence criminal conduct, and the civil side offered no emergency relief from the constant harassment and violence of spouses seeking to compel reconciliation or punish a spouse for "abandoning" the marriage. Visionary attorneys and advocates, professionals dissatisfied with the cold shoulder of the law and committed to achieving safety and justice for clients, conceived of a remedy that would offer temporary relief to victims of domestic violence -- civil protection orders. In the ensuing years, every state, some Indian nations and most territories have adopted a civil protection order code to protect the vulnerable adults and children subjected to violence and coercion by family and household members.

Unfortunately, protection order codes are not seamlessly self-implementing and perpetrators have not consistently complied with the mandates of protection orders. Studies have since suggested that about 75 percent of those constrained by protection orders comply, at least to the extent that victims do not ask the courts to impose penalties for non-compliance or that law enforcement does not arrest for violation of orders. This level of compliance appears to be most likely in jurisdictions where access to the courts is immediate, where orders are tailored to the particular safety, autonomy and economic requirements of victims and where police enforcement of orders is swift and certain. The defendants who do not comply (at least 25 percent) pose serious risk to victims. Experience and research have revealed that some batterers utilize escalated strategies of violence and coercion once victims determine to separate. These batterers invariably believe that they are entitled to a relationship with their victims. They assert almost an inalienable ownership interest in their abused partners and believe they are entitled to oversee and control the lives of the women they batter. Many fervently believe that they may legitimately use force, threat, coercive tactics and violence to control their partners and maintain relationships. They are simultaneously terrified of the loss of access to, relationship with, ownership of and control over the women they have abused. Many are desperate and thus defiant. Those batterers who search for, pursue, track, stalk and engage in surveillance of victims, may be the most dangerous to victims and to those who would protect them.

Victims, who recognize the dangers posed by batterers refusing to follow the dictates of protection orders, sometimes decide to relocate to hide from the abuser or to obtain better support and protection. These women require protection in the communities to which they relocate, including enforcement of protection orders issued in the home jurisdiction. Other protected persons live their lives in several jurisdictions. Women who reside on the borders of counties, states and Indian nations invariably live parts of their lives outside the judicial district where their protection orders are issued. They work, shop, attend church, visit relatives, recreate, etc. in jurisdictions outside that where the protection order was issued. They sometimes increase their activities outside the home jurisdiction to avoid contact with batterers. They require protection in these foreign jurisdictions. Notwithstanding the need for foreign enforcement of protection orders, few victims have been able to readily obtain police intervention and enforcement of protection orders outside of the issuing jurisdiction. In recent years, some states have passed statutes, devised procedures and employed technology to offer protection to non-resident victims. Until the passage of the FFC provision in VAWA there was little public discourse and even less political commitment to enforcing protection orders issued in other judicial districts.

Victims of domestic violence find protection orders useful tools in their pursuit of safety and justice only when enforcement is certain. Where there is uneven or unpredictable enforcement by police and courts, battered women live in terror and must turn to self-help methods, most lawful but some illegal, to protect themselves, their children and others who intervene to stop abuser violence. Only where law enforcement and judicial response is sure, swift, sufficient, sustained and designed to safeguard and support victims will battered women be able to rely on the legal system for survival.

FFC is an important tool in the array of legal remedies available to intervene in the concerted, instrumental, desperate and elevated violence of batterers who cross county, state, tribal and territorial boundaries to violate protection orders in an attempt to punish victims for leaving relationships or to coerce them into reconciliation. This a cursory outline of the reasons that communities might vigorously join the ranks of those seeking to provide FFC to foreign protection orders. The rationale will not persuade all, but it may invite some who are resistant to enforcing orders to examine their practice, to consider the likely consequences of denying justice to vulnerable victims, and to design reform initiatives to offer "outsiders" the protection to which all residents/citizens of the jurisdiction are entitled.

Resistance to enforcement of foreign protection orders will not evaporate merely with the communication of the above. The sources of resistance are more profound. One relatively invisible source of resistance is that of xenophobia, significant bias against those "from away." People from other places are too often not viewed as having a legitimate or equal claim to the protections of the enforcing jurisdiction as do the citizens of that community. The strength of this provincialism was brought home to me a number of years ago when a battered woman who resided in Pennsylvania and worked in a neighboring state was killed by her stalking husband outside of her place of employment. She had received a protection order from a Pennsylvania court. She could not get the protection order enforced across the state line where she worked, was not able to domesticate her order in the neighboring state, was not eligible for a protection order in that state and could not persuade the police to act on her behalf. The newspapers in Pennsylvania were filled with the anguish of the domestic violence advocates, her attorney, the Pennsylvania police, courts and her family and co-workers. The newspaper across the state line engaged in protracted victim-blaming and rationalized their failure to protect her by pronouncing the homicide inevitable. She was mourned in her home state and vilified in the neighboring state. The strong preference accorded locals over strangers was sharply told by the diametrically opposed responses of the two neighboring communities. Until the legal system in all judicial districts fully protects guests, as well as residents, justice will be denied or meted out in smaller portions to those we deem strangers. Yet, in an increasingly mobile society, we are virtually all strangers much of the time, potentially requiring the safeguards of each community in which we find ourselves. We must forsake provincialism and disparate justice.

Another source of resistance appears to be the reluctance to change. Old practices are comfortable because they are known. They move forward with the force of habit, and are cloaked in the mantles of propriety and apparent efficacy. Change is not easy. It may require shifting priorities. It certainly requires design, experimentation, evaluation, re-tooling and lot of learning. Significant change of policy and practice will be necessary to fully implement VAWA's FFC mandate. An additional cause of resistance for some may be that to fully or effectively implement the FFC provision of VAWA requires mechanisms or resources that are beyond the reach of some communities. Invariably, resistance to enforcement is articulated around potential liability for law enforcement arresting those whom officers believe to have violated protection orders. Many officers are reluctant to act or have been directed not to arrest unless they can verify that a valid protection order is operative in another jurisdiction. The scepter of liability looms large. One final stumbling block to enforcement of foreign protection orders may be the traditions of law enforcement and court administration that are procedure-driven rather than problem-solving. Especially in the early stages of FFC implementation in this country, the approach of law enforcement and the courts must be one of problem-solving rather than reliance on definitive policy directives. The approach of professionals asked to assist battered adults and children in their search for safety and justice must be one which seeks to identify problems, to generate strategies for effective intervention and to develop solutions that are sure, swift, sufficient, sustained and that prioritize victim safety. Once these solutions have been employed and tested, communities will be able to incorporate them into policy and procedure. This formal adoption of FFC-enabling procedures will significantly routinize effective practice and enable all professionals to confidently act to enforce protection orders. However, even with this institutionalization, the challenges of FFC will not totally recede; additional barriers will emerge and they must be met with a problem-solving approach to assure that all vulnerable adults and children receive the safeguards promised in their protection orders.

Although many of us might wish for a cookie cutter approach to enforcement of foreign protection orders, wishing for a piece of equipment that we could weld into place, turning on the switch for seamless enforcement to be produced in an assembly-line manner, such a simple solution is not ever going to be available. Rather, for many years to come we must employ a problem-solving approach to FFC implementation. We must seek and celebrate incremental change. Communities may construct solutions that differ, as varying strategies are tailored to fit within the context of dissimilar jurisdictions. Divergent strategies, however, must be communicated and coordinated with other judicial districts within and between states, tribes and territories. Linkages and mechanisms for spanning the differences will have to be employed. Achieving these will require significant political will and meticulous problem-solving efforts.

Dialogue among advocates and colleagues in the legal system is the place to start. Conversations with battered women will enhance the discourse. Identification of barriers to ready enforcement of protection orders and of corresponding solutions will emerge from these communications. Strategies for effecting essential system change will become apparent. Resources can then be located and employed. The resulting systemic reforms can be tested, modified and adopted. Training of all personnel involved in enforcement of foreign orders must follow, emphasizing both the problem-solving approach and the importance of justice for strangers and neighbors alike. While many barriers to FFC of protection orders will fall to this deliberative examination, design and implementation, new barriers or problems will occur and these must be addressed in a similar fashion. Eventually, we can achieve a seamless enforcement system across jurisdictional lines. And it may be that the finished product will be universal in form and practice. Meanwhile, to sustain energy and focus, each community working to implement the FFC provision of VAWA must acknowledge the significant strides each has taken toward achievement of a seamless system of local and foreign protection order enforcement.

Participants in the numerous seminars and conferences on FFC in which I have served as faculty in the last year, universally said, "It looks so simple, but it's incredibly hard to implement. We want to, but we're having trouble. Help!" The following describes some of the implementation issues reported to me and suggests preliminary strategies for enhancing implementation of 18 U. S. C. 2265.

Many practitioners reported that the FFC provision of VAWA was not even "on the screen" of key policy-makers within their jurisdictions. They concluded that until FFC implementation was a priority for leadership at the local level and beyond, uneven implementation would continue and the sharp variety of response between jurisdictions would pose grave risks to victims seeking enforcement.

National conferences like Full Faith & Credit: A Passport to Safety (offered by NCJFCJ, BWJP, DOJ, SJI, NCSC, CCJ and COSCA) and the Seventh Annual Domestic Violence Conference (offered by NCDA) provide a unique opportunity for state and local multi-disciplinary teams to learn together. Team learning facilitates team-building for enhanced local practice. The STOP TA Project (funded by DOJ) provides national and regional conferences for state STOP administrators and STOP subgrantees which regularly include workshops on FFC under VAWA. Mending the Sacred Hoop (funded by DOJ) likewise offers seminars to Indian tribal/consortium grantees about FFC. The American Bar Association produced a video and instructional handbook on VAWA. VAW Web, a WebPage targeted to STOP grantees and legal system professionals, debuts in October, 1997 and will first address FFC of criminal and civil protection orders. Address to be announced, and this material will be linked to the Website of the VAWGO office (http://www.ojp.usdoj.gov/VAWGO). This marvelous book is also a resource for professional education. It will be distributed at Full Faith & Credit: A Passport to Safety and can be downloaded from the VAW Website the beginning of November. For information on how to access these materials, call the FFC Project at 800/903-0111, ext. 2 or <<gjp@pcadv.org>> and ask to speak with Gail Pertschi.

In most jurisdictions criminal protective orders are either included in conditions on release or in victim-witness protective orders. The specifics of these orders, e.g. stay away, no contact, firearm surrender, counseling, drug and alcohol screens, etc., are not directed to law enforcement and victims infrequently receive a copy of the conditions/orders. The criminal protective orders are not placed in an electronic database available to police officers. Furthermore, codes seldom give law enforcement the authority to make a warrantless arrest when an officer has probable cause to believe that a defendant has violated one of the provisions of these orders.

While making and distributing copies of criminal protection orders to victims is probably the easiest of these solutions to institute, even this simple strategy requires significant stretches in practice from justice system actors. Police would have to acquire "contact information" from victims for follow-up. This means obtaining several addresses. These contact locations and people must not be included in the public record to prevent stalking and retaliation, yet they must either be conveyed to the arraigning authority responsible for victim notification or the police must assume the responsibility for advising victims of the conditions on release. Victims should be apprised of procedures they must follow to achieve enforcement of orders should the alleged perpetrator violate the orders. Police officers do not enjoy the authority of warrantless arrest in many jurisdictions for violation of bail conditions unless the violation constitutes another substantive crime. The lack of authority discourages police from enforcing "stay away" orders because the administrative procedures are onerous or make immediate arrest impossible. Thus, these conditions are too often "not worth the paper they're written on." Statutory authority for warrantless arrest for violation of bail conditions may restore power to these conditions. Local and state police registries of protection orders are almost universally designed only to contain civil protection orders. The content and format of criminal protection orders is often very distinct from civil orders. Part of the problem is that the orders issue from different sectors of the courts which have never sought to integrate or link their data systems. Unless police can verify conditions on release or criminal protective orders and understand which conditions, if violated, subject the suspect to arrest, they are likely to ignore all but the most egregious violations.

As a culture, we are highly ambivalent about imposing any restrictions on the ownership and possession of firearms. Notwithstanding the fact that federal and state law include restrictions on firearms acquisition and possession for various classes of persons (e.g., the Gun Control Act of 1968 precludes the acquisition/possession/ownership of firearms and ammunition for convicted felons, fugitives from justice, unlawful users of controlled substances, persons adjudicated as mental defectives, illegal aliens, persons dishonorably discharged, those subject to restraining orders and those convicted of domestic violence misdemeanors), judges are reluctant to impose firearms prohibitions in civil and criminal protection orders, and law enforcement (local, state, tribal and ATF) are equally reluctant to enforce orders related to firearms relinquishment or seizure.

Many police and judges do not know that most persons against whom there is a criminal or civil protection order, arising in the context of domestic violence, are precluded by federal law from possessing firearms and ammunition. Professional education about local, state and federal firearms codes is an essential stepping stone for improved practice related to firearms. Judges are rarely apprised of the extent of firearms threats, intimidation and usage by batterers. Affidavits specifically crafted to inform the court of the defendant's possession of firearms, and the defendant's history of utilization of firearms might be included in pleadings for protection orders. In the litany of notices to defendants about the consequences of violation of protection orders, highlighted notice should be given that possession, failure to surrender, transfer and/or acquisition of firearms may subject the defendant to federal prosecution and incarceration. Judges should specify in protection orders whether a defendant is subject to the federal prohibitions related to guns in 18 U. S. C. 922 (g) (8). Police officers are not able to assess whether a particular person against whom a protection order has been issued fits within the class of persons prohibited, and they cannot assess whether the court has included the requisite findings in their orders or whether the defendant was accorded due process. These determinations must be made by judges, preferably by the issuing judge, and an indicator should appear on the face of the order and in the police registry of protection orders, stipulating that the issuing court has concluded that the defendant is subject to the federal firearms and ammunition prohibitions. Police, sheriffs and other law enforcement should be guided (and protected) by protocols that outline their responsibilities and authority for search, seizure, confiscation, storage and return of firearms pursuant to local, state and federal law. Storage of these confiscated weapons (and there often are many firearms per prohibited person) has become a problem. In Delaware, the storage problems are now a thing of the past, as the confiscated firearms are now being stored at low cost in climate-controlled facilities at National Guard enclaves. ATF has not yet announced a procedure by which local law enforcement can deliver guns prohibited by federal law to federal storage facilities. Storage should be made available whether or not federal prosecution is pending under VAWA or the Gun Control Act of 1968, 922 (g) (8) or (9). Federal storage will offer significant assistance to local departments. Because of the reluctance to issue and enforce firearms prohibitions, advocates in some jurisdictions have initiated "firearms confiscation watches" similar to court watches; to ascertain current firearms practice, to identify problems and offer recommendations for systemic reform.

Attorneys, advocates and court personnel who assist battered adults in preparing petitions or affidavits for protection orders do not routinely inquire of victims whether they are likely to require enforcement in other judicial districts. Nor do they tell battered women what must be done to assure sure, swift, sufficient, sustained enforcement in other jurisdictions. Often these professionals do not know themselves.

Battered women should be given written directions on enforcement in the issuing and in foreign jurisdictions. At the very least, this might include contact information about the law enforcement agency which provides 24 hour verification of valid orders in the issuing jurisdiction, access information about any state registry of protection orders, information about whether the state is participating in the protection order file of the FBI (NCIC), and confirmation that the order has been placed in any/all of these registries. Battered women should be alerted to the possibility that their paper orders will not be honored in foreign jurisdictions unless they have followed procedures established by the various communities where they may seek enforcement. Battered adults should be told to take a certified copy of the protection order to the court clerk in any jurisdiction where enforcement may be required (i.e., where she works, attends church, visits family, etc.) and ascertain the procedures that should be followed to increase the probability that her foreign order will be vigorously enforced. Referral to domestic violence programs in the foreign jurisdiction is also recommended. These programs may be able to offer advocacy for FFC. However, counsel of record should go beyond referral. They should make the inquiries and furnish the requisite paperwork to the designated offices in the foreign jurisdictions. Should counsel or advocates learn that a foreign jurisdiction does not have procedures for enforcing foreign orders, they might work with Legal Services attorneys or domestic violence programs in the foreign jurisdiction to assure compliance with the FFC provision of VAWA. Assistance in efforts to identify or craft systems for FFC in the foreign jurisdiction (including within the state, not merely across state, tribal and territorial lines) may be obtained from the FFC Project at 800/903-0111, ext. 2; ask to speak to Seema Zeya.

Police officers called to the scene of an alleged violation of a protection order, particularly those issued in other jurisdictions, too often are not able to readily verify the validity of an order.

A significant majority of the states have established or are developing statewide police registries. These greatly facilitate intra-state verification efforts, and most responding officers have received sufficient training to be able to access these repositories. However, responding officers are not now able to verify foreign orders issued in most other states, tribes or territories because the necessary links between state and local databases have not been electronically established. Therefore, methods for contacting the local or state registry in which the issuing court's orders are deposited must be included clearly on the face sheet of each order. Unless verification is simplified, officers in foreign jurisdictions may not arrest for protection order violations absent severe violence that can be charged independent of any protection order violation. NCIC is now operative, but it is only as good as the local or state registries that gather and electronically format the requisite information. Just a handful of states are now participating and not all the orders issued in those states are necessarily included. NCIC requires identifiers, including SS# and date of birth of the defendant, for a protection order to be included in the NCIC protection order file. Those state orders that do not include sufficient identifiers are not included in NCIC. This does not mean that the orders are invalid. It does mean that NCIC is not a reliable system for verification unless orders specify the requisite identifiers. For this to occur, courts will need to start capturing and recording this information. Courts might utilize the Certification Form, developed by the FFC Project above, as a cover sheet for issued orders. It will facilitate extraction of essential data elements for local, state and NCIC protection order registries. Another challenge that remains in many states is that there may be significant delays between issuance and inclusion in the registry. The capacity of courts to electronically transmit orders will enable timely inclusion; this is critical as violation of orders often occurs immediately after service on perpetrators. Another barrier, that may require statutory reform, is the lack of authority for police to rely upon electronic (rather than paper) orders for verification. As registries become electronic, this authority must be made explicit.

Several problems have been identified related to service of protection orders. First, batterers are skillful evaders of service. Evasion is easy in jurisdictions where process servers work only during business hours and rely upon traditional procedures and resources for services. Further, when service is achieved, proofs thereof are not routinely furnished to registries or the enforcing authorities. Officers responding to a domestic violence call, where a victim alleges violation of a protection order and the defendant denies service, often effect service on the defendant by handing him a copy of the order furnished by the victim. He is then told that any future violation will be met with arrest and prosecution. While this is an efficient method of service, too often officers do not then file a proof of service and/or local and state registries do not make notation that services has been accomplished. Thus, when the victim seeks enforcement of an order that has been served, the registry does not confirm that service was made. While VAWA directs that victims of crimes of domestic and sexual violence not be liable for the filing fees and costs related to criminal conduct and process, including the costs of service, in some jurisdictions, victims are still required to pay service costs before the process is initiated. After the passage of VAWA, many states amended codes, rules or regulations to waive service costs. Although most of these directives were silent on the question of whether service costs were to be waived for non-residents seeking service of foreign orders on defendants, many states, tribes and territories charge service costs for service of foreign orders upon defendants residing in or temporarily located within their borders. This creates enormous financial barriers to battered adults seeking service of orders in non-issuing jurisdictions. For most, the consequence is that the order either is terminated for failure of service or that it is unenforceable because due process has not been accorded the defendant.

Every judicial district should devise procedures for service of protection orders. These should incorporate strategies for service of the illusive defendant and prioritize protection orders as emergency service and proof cases. Provision should be made for service outside the business hours of the court. Proof repositories should indicate the date and time that actual notice has been achieved where service is delayed. Notice notations might be removed from the service repositories upon subsequent filing of the requisite proofs of service. All persons authorized to serve and provide proofs of notice and/or service should be trained on the procedures and on filing with proof repositories. Tribal and state codes and court rules should specify that protection orders of issuing courts and of foreign courts should be served on defendants without payment of costs by battered adults or their guardians. Procedures for affecting service of foreign orders without cost should be developed and made available through courts, police, advocates and bar associations. The system for filing proofs of service should be simplified so that all authorized to serve process related to protection orders (which may include sheriffs, police officers, counsel of record, civil process servers and victims) can quickly file proofs, including electronic proofs. These proofs should be susceptible to timely confirmation by enforcing officers through electronic or paper verification. Court administrators should monitor and seek compliance with the service and proof directives in the jurisdiction. As an interim measure, the Sheriff in one county in Florida has devised alternative approach to confirmation of service. He drafted a form by which the plaintiff can affirm under oath that the order was served on the defendant. The form also permits the defendant to dispute, under oath, the victim's assertion of service. One problem identified with this strategy is that victims cannot be held to a knowledge of the distinction between notice and service.

At virtually every conference on FFC of protection orders, participants reported that ATF and the FBI are either uninformed about or resistant to the provisions of VAWA and the Gun Control Act related to domestic violence perpetrators. Few report that the U.S. Attorney has initiated communication with local prosecutors and advocates about implementation of VAWA.

Plans are in the works to train ATF and FBI leadership about domestic violence and their respective responsibilities under VAWA and the recent amendments to the Gun Control Act. The Department of Justice has awarded a grant for training and technical assistance for Assistant U.S. Attorneys. In January of 1997, each U.S. Attorney identified a "point of contact" within each district. These may be an Assistant U.S. Attorneys (AUSAs) or the victim coordinator within the district. An excellent seminar was offered in January of 1997 to AUSAs from around the country. It was orchestrated by Margaret Groban, an AUSA from Maine and a contributor to this volume. In several federal districts dialogue and agreements for coordinated response to domestic violence have been devised between local and state police, prosecutors, court administration and advocates. The Western District of Kentucky was the first to take leadership on the issue of FFC of protection orders. The Kentucky FFC Project of the Kentucky Domestic Violence Association (KDVA) labored throughout the Commonwealth of Kentucky to establish viable working relations between the federal and state authorities. The exemplary work of KDVA continues.

When a batterer crosses state/tribal/territorial lines to violate a protection order, prosecution may be brought in the issuing jurisdiction, in the jurisdiction where the violation occurred and in the federal district courts in both locales. A decision must be made. Communication about that decision should occur. There is now little dialogue between the issuing and enforcing jurisdictions and the federal authorities in either community about this decision-making. Sometimes prosecution is foregone when another enforcing authority might appropriately pursue charges against the stalking batterer.

Unquestionably, the local prosecutor in the community where the violation happened can decide to pursue charges without contacting or considering the other potential venues for prosecution. However, s/he might want to carefully consider the advantages and disadvantages of a decision for exclusive enforcement. While it is unlikely that the issuing state/tribe/territory will extradite for a misdemeanor committed in another jurisdiction, it may choose to pursue prosecution if the violator returns to the issuing venue within the statute of limitations. When a batterer has eluded prosecution or is considered to be highly dangerous but subject only to minimum sanction at the local or state level, federal prosecution might offer the victim and community elevated protections -- longer incarceration or more stringent probation/parole. Inter-jurisdictional communication can enhance victim safety and batterer accountability in several ways. Conjoint deliberate review of the various prosecution fora by all potential prosecutors may result in strategic decision-making that will heighten the probability of successful prosecution and enhance the safety of victims. Consideration of the interests of victims in prosecution in one venue rather than others may limit the disruption and inconvenience to battered women that prosecution in foreign jurisdictions may cause. Communication by prosecutors with judges in issuing jurisdictions may provide prosecutors in enforcing jurisdictions with critical information that will enhance prosecution. Issuing judges are often concerned about the victims for whom they've issued orders and may factor information from convictions for violations in other jurisdictions into their deliberations should an abuser come before them again with an application for modification/suspension or pursuant to additional violations in the issuing district. Pam Paziotopoulos, Chief of the Domestic Violence Unit of the Cook County State Attorney's Office, wrote a thoughtful piece entitled Violence Against Women Act: Federal Relief for State Prosecutors that was published in The Prosecutor , Volume 30, No. 3, May/June 1996. The article considers potential conflicts between state and federal authorities related to investigation, venue, charging, trial issues and double jeopardy. It also describes why federal prosecution may better serve the interests of justice and safety for battered women and children and calls for communication and cooperation between federal and state law enforcement and prosecutors. These are but a few of the issues raised and solutions advanced by participants in FFC seminars and workshops over the course of the last year. Continued problem-solving and exchange is invited among all those seeking to implement the FFC provision of VAWA. The FFC Project of PCADV will share your problems, strategies and innovative solutions with other policy-makers and practitioners around the country, in tribal nations and with territorial governments. Keep up the discourse. Send your conclusions to the FFC Project, PCADV, 6400 Flank Drive, Suite 1300, Harrisburg, Pennsylvania 17112, 800/903-0111, ext. 2 (phone), 717/671-5542 (fax), and JustProj1@aol.com.